It is my ‘feeling’ that with some individuals, the profit motive can lead to problems. But I have disciplined myself not to let such feelings or biases interfere with objectively examining issues.

Richard F. Hoyer

That is not a feeling - that is an assessment. Respectfully I question the specious use of words like feelings and emotions without being able to identify them.

You have mentioned before in other threads like this 'disciplining' yourself to not include feelings in issues that involve taking animals out of the wild. Our decisions to refrain or partake of any action are dimensional thought processes.

A refined sense of profit induced behavior, because of experiencing examples of that behavior, as an operative in decision making isnt a "feeling".

I don't know what the percent of occupied chuckwalla habitat is in Nevada. Chuckwalla's in Nevada are patchily distributed in extremely rocky habitats, so there is a lot of unoccupied habitat. If only some entity, some management agency could address these gaps in distribution. Perhaps through predictive modeling. And then that agency could try to enact science based management through a data collection and analysis process?

I also take some issue with your description of population dynamics. Its badly outdated. In areas of contiguous habitat and populations your model has some validity but even there its the exception not the rule. Your model of one lambda-one population at equilibrium isn't used to manage big game in the west. All the western states have moved toward discrete management units to better manage wildlife at meaningful population units. And by doing this they maximize sustained yield. I feel like the issues and assumptions with your descriptions of population biology have been described to you time and time again but you still cling to an outdated 1970s management paradigm.

I also take some issue with your stance that you are unbiased and your responses are not influenced by feelings or emotions. We all bring our feelings and emotions to the discussion. This includes scientists, hobbyists, collectors, and land managers. And folks on this forum.

With commercial collecting is our scientific threshold really "If collection is unlikely to drive that species to extinction, we are OK with it"? Can we not recognize there are lots of other ecological (indirect effects, trophic cascades, gene flow), recreational, and social considerations?

Jeroea,An additional clarification: There is a basic principle of populations that explains why species tend to remain at equilibrium and neither increase or decrease in an appreciable manner.

An example I have given in the past is that despite worms having exceeding high reproductive rates, we do find ourselves being over run by worms. That principle indicates the yearly attrition (death) from all sources, approximates the mean reproductive output for most species. It that were not the case and the survival of worms each year had been a tiny percentage above the level of attrition, by now we would be up to our knee caps or eyeballs in worms.

: There is a basic principle of populations that explains why species tend to remain at equilibrium and neither increase or decrease in an appreciable manner.

A basic principle maybe but by no means a law or even a rule. I asked earlier why there are no chuckwallas in Northern Nevada? Its because there is a point in the distribution of chuckwallas where mortality exceeds reproduction. This disequilibrium in population dynamics is occurring over vast areas. Is the population at equilibrium or dis-equilibrium? It depends on where you look.

I don't know what the percent of occupied chuckwalla habitat is in Nevada. Chuckwalla's in Nevada are patchily distributed in extremely rocky habitats, so there is a lot of unoccupied habitat. If only some entity, some management agency could address these gaps in distribution. Perhaps through predictive modeling. And then that agency could try to enact science based management through a data collection and analysis process?

There is also a lot of occupied chuckwalla habitat in Nevada. It should also be noted that. Extremely rocky habitats= extremely difficult to collect. And why has this suddenly become centered around Chuckwalla's ? This reptile regulation tightening proposal is inclusive. Predictive modeling has proven to be a POOR indicator for determining potential reptile distribution and populous.

In 1989 the NDOW temporally banned the commercial collection of reptiles without evidence. Ultimately by 1990 the Nevada commissioner's board agreed with the collectors and ordered the NDOW to handle reptiles by using a process similar to that for furbearing species including detailed collection logs that would provide distribution and relative abundance information. Since that 1990 commission order thru today the NDOW has done everything possible to discredit the impute of the collectors. Not once has the NDOW provided credible evidence to justify this. As of last yr. the decrease in collectors from its peak is down by more then 75% and the total take is down by more then 75% from it peak and its likely to drop. But the key statistic is that the average number of animals and species taken per collector has remained constant. You have as much chance of finding any of the collected species today as you did 30yrs ago. The recorded data shows that collection has demonstrably changed nothing.

Ernie Eison

PS Richard, I completely understand.

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Submitting documentation and providing testimony before the Calif. and Oregon Wildlife Commissions has been a complete waste of energy and time. The Commissioners put complete trust in what the agency biologists tell them.

The truth is you didn't even get 3 minutes. The Commissions were legally forced to sit there for the extra 3 minutes you were given. They would have paid more attention to you if just stood there talking about the traffic downtown. Its absolutely disgusting.

Now back to more regularly scheduled, productive disagreement....Predictive modeling may be poor (in your opinion) but relative to what? Not having a model. A range map? Expert opinion? Those are still models, predictive modeling tries to take all the information we know, keep everything transparent and make the most scientificly supported guess possible. I suspect chuckwalla distribution would be relatively easy to model btw.

I know you felt betrayed by the python modeling but wasn't that rescinded or at least challenged in the literature?

Jeroea,“If you just don't collect, it will (obviously) usually be even better.” I ask, why do you believe that to be the case?

Consider that humans are just one of many predators of ‘prey’ species.’ So would be better if no predators removed any prey species from the wild? And why single out just humans taking ‘prey’ species and not mention other predators? Is the predation by humans inherently bad but the predation by other predators just fine? Of course, history had shown that humans can deplete prey species far better than other predators.

There are some concepts / principles that pertain to your statement that you might consider. One is called ‘carrying capacity’. And its companion principle or concept is that ‘wildlife cannot be stockpiled’. As a general rule, the landscape can support just so many of any particular species at varying times of the year. And above a certain threshold in numbers when that sometimes happens, there occurs a die-off (often starvation) as species outstrip their food resources. This usually occurs during the winter months when food resources are at their lowest.

Responsible ranchers that pasture livestock are acutely aware of carrying capacity. Too many of any type of livestock on a parcel of land will lead to over grazing and if not caught in time, the death of livestock as they run out of food resources. The same scenario has been documented for some species of wildlife. I believe beaver and elephants have been known to decimate their food resources and suffer much higher than normal losses in their numbers as a result.

You mention the ‘precautionary principle’ so can you tell me about it?

Jeroea,An additional clarification: There is a basic principle of populations that explains why species tend to remain at equilibrium and neither increase or decrease in an appreciable manner.An example I have given in the past is that despite worms having exceeding high reproductive rates, we do find ourselves being over run by worms. That principle indicates the yearly attrition (death) from all sources, approximates the mean reproductive output for most species. It that were not the case and the survival of worms each year had been a tiny percentage above the level of attrition, by now we would be up to our knee caps or eyeballs in worms. Richard F. Hoyer (Corvallis, Oregon)

Sure, but that's a rather theoretical assessment, not taking the pressures I mentioned into account. Or the opportunities - new resources may cause exponential population growth (as in invasive species, after a usual lag phase).

You mention the ‘precautionary principle’ so can you tell me about it?

Very simple. You don't need to know whether the population is in sufficient health (by gaining knowledge on population dynamics, allele diversity and whatnot) to deal with take, if you leave it alone.

The average status of reptile populations may differ quite a bit between Europe and the US, those in Europe being worse off. Maybe that makes me more careful. Generally, I agree that collecting is way too often branded as a serious threat. Maybe it's a sentimental thing, maybe it's because it's easier to bully some individual humans wanting to keep a few animals rather than dealing with real conservation issues.

Predictive modeling may be poor (in your opinion) but relative to what? Not having a model. A range map? Expert opinion? Those are still models, predictive modeling tries to take all the information we know, keep everything transparent and make the most scientificly supported guess possible. I suspect chuckwalla distribution would be relatively easy to model btw.

I know you felt betrayed by the python modeling but wasn't that rescinded or at least challenged in the literature?

There are no scientifically reliable ways to accurately estimate reptile population's in most instances but there are reliable ways to produce misleading numbers using any method of estimation. Egregious examples involved your USGS buddy's Gordon Rodda and Robert Reed. Yes the python modeling was challenged, chastised and debunked by scientist around the world. But you cant disprove a guess with another guess. The USFW gave Rodda and Reed a large commission to strategically use manipulated modeling to produce an equally egregious Risk Assessment. Then the USFW basically gave everyone outside of the USGS / USFW circle of friends the finger.

A second and common misuse of population survey (also employed by Rodda/Reed). Involves collection sampling and pro-rating. Exmaple : Biologist Frank MAZZOTTI: The pythons are definitely concentrated in certain locations in the Everglades, but they are fairly widespread.

What Rodda and Reed did was they used collection sample's from a concentrated area and then pro-rated this sampling across the entire wide range, creating a population estimate dramatically larger then the actual numbers. This can be done in reverse to minimize population numbers. It is OBVIOUS that based on the over the top bias displayed in their "data" presentation. The NDOW and their biologist could never be trusted to produce honest and reliable population estimates.The state of Nevada has years of collection logs that demonstrate population consistency to draw upon. The Nevada board of wildlife commissioner's specified that the use of these logs was to provide distribution and relative abundance information. In the same way collection logs are used for monitoring commercial furbearer trapping in Nevada. Jason Jones clearly distorted the collected facts found in these logs to deceive the commissioner's panel.

- they are non-regulatory; designation in a SWAP as a "Species of Greatest Conservation Need" (SGCN) does not confer any additional management status (which can only come through specific agency rulemaking; I am unaware of a single state which has decreed by rule that SGCNs get some kind of management designation)

- they allow states to come up with whatever SGCN inclusion criteria they want; the criteria can be as explicit, repeatable, transparent, evidence-based etc as a state wants - or they can be totally subjectively hand-picked

- you would need to actually read the SWAP to see what criteria were used; better SWAPs describe their methods, well, better than lesser SWAPs do

- SWAPs get reviewed and revised every 10 years at the longest; methods and contents change quite a bit over time - SGCN lists change too

- the intent of SWAPs is to get ahead of Endangered Species listing crises - to 1) determine which species might be headed into the listing pipeline, 2) determine what sorts of actions are required to get out of that pipeline, and 3) get those actions taken

- the "petitioning enviro groups" often invoke "too little data or knowledge" in their petitions; many SGCNs are in SWAPs because the agencies feel there might be cause for concerns, while many are in SWAPs simply because too little is known

Field herpers can help the latter situation. It is easier for them to help if the agency has a friendly posture. NDOW has an incredibly friendly posture towards field herpers and the data they provide. Just as an example, I personally am signed up as a state volunteer, and when I come herping down there in spring, I am permitted to capture Gila monsters for brief photo, measurement, and blood-draw sessions. Several other people on this forum have similar participation status with Gila monsters in NV. Together we have greatly increased the knowledge base about these lizards in the state. It feels good to help out, and we also are left feeling better about the status of these animals in the wild, in NV, for now (a drying climate has the possibility of being very bad for Gilas, because they are not very water-tight).

Herpers trashing NDOW staff is not going to do much to maintain that friendly posture.

*********************************

As for the commercial collection numbers from NV - this is a fundamental part of the problem. The reported numbers are definitely biased low. Data are being collected right now to substantiate and hopefully quantify this claim. Like I said before, I don't support an end to commercial collection in NV, but it has to be better-managed. This is far from being NDOW's fault; they may share a little bit of the responsibility, but THE ONLY WAY for harvest management to have a scientific basis, is for actual removal numbers to be reported. Removal = live harvest + trap mortality, of target as well as non-target individuals. The licensees in this case are using illegal methods of take (e.g., pitfall traps), are operating them outside the permitted seasons (24/7/365, apparently for years), and these methods are causing a lot of unreported mortality (as well as in all likelihood producing the majority of reported harvest).

If a ban or other management restriction is instituted, it will be much more the fault of the scofflaws, than it will be due to enviro-group OR STAFF input. The enviros really can't make NDOW or any other western wildlife agency do much (the agencies pretty much LOATHE them). OTOH user groups systematically breaking the law, for extended periods of time, is something "the agencies" (their Commissions + Directors + staff) are very likely to react very strongly to.

Remember that Commissions are the deciding power in the agencies, not staff. Not even so much Directors - usually they just sit on the Commission as a non-voting "secretary" or "subject-matter expert". Ideas can come from stakeholders or staff - ideally they come from a functional partnership of staff + stakeholders. Presumably the reason the scofflaws haven't been slammed yet, is 1) they've had the protection of one or more Commissioners over the years, and 2) staff have been reluctant to face up to such power. To me, Jason deserves a lot of credit just for getting this issue back into consideration. Nevada herpers need to get beside him - guiding him some if they don't want a ban, helping him if they do. He needs to be allowed to act as a manager in this situation, and not be misidentified (by others, or by himself) as a stakeholder (beneficiary) or decisionmaker (trustee).

Again, my preference as a nearly zero-stake outsider is for commercial collection to be allowed to continue. But not in its present, Wild-west outlaw form - I'd rather see some rotating closed areas, better compliance with the law, some kind of quotas or caps on the larger-bodied, slower-reproducing taxa, and finally more research that will be used to inform future harvest management. Basically, get the herp management more in line with how bobcats, otters, forest grouse, and other poorly-known taxa are managed. Nobody can manage (research, monitor, and harvest) herps as intensively as deer or trout, but "wide open or closed shut" is a pretty crappy choice of options. We can do better, we should do better.

NDOW has an incredibly friendly posture towards field herpers and the data they provide.

This is not true. For decades the NDOW has targeted the handful of reptile collectors that reside in the state. The NDOW has proven themselves untrustworthy by relying on an approach that involves more shock value then science. Essentially they have made a concerted effort to railroad a small group of individuals without credible provocation. And this time is no different. I applaud these people for standing up to the NDOW corruption that try's to masquerade as science based conservation.

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As for the commercial collection numbers from NV - this is a fundamental part of the problem. The reported numbers are definitely biased low. Data are being collected right now to substantiate and hopefully quantify this claim.

NDOW biologist Jason Jones says the collectors are catching less not more. As I pointed out and detailed in a prior post. In his presentation entitled: A year in the life of a collector. Jones bent over backwards in applying a misleading representation of collection data. No doubt this will also be the case in future presentation's of collection data. By supporting this the NDOW have proven themselves unreliable.

It isn't hard to notice NDOW supporters. Have side stepped and failed to address any of the points involving NDOW biologist Jason Jones blatant use of misleading information, contradictions, suggestive use of photos and captions. His common theme of using shock value elements that have NOTHING to do with situation at hand and his complete lack of scientific support. NDOW biologist Jason Jones has clearly been more activist then scientist.

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The average status of reptile populations may differ quite a bit between Europe and the US, those in Europe being worse off. Maybe that makes me more careful. Generally, I agree that collecting is way too often branded as a serious threat. Maybe it's a sentimental thing, maybe it's because it's easier to bully some individual humans wanting to keep a few animals rather than dealing with real conservation issues. Jeroen Speybroeck

I would like to know what percentage of commercially collected herps are destined for Petco, which has overwhelmingly become the dominant face of reptile retail today.

I know alot about what happens to herps there, how they run things and corporate budget their care - right down to scrimping on the numbers of weakened, stinking crickets the employees are allowed to feed the animals, energy expenditure on providing heat and environmental details. I created a custom niche of setting up and providing consult at a Non Petco shop - an independently owned exotics shop - an endangered dinosaur today - where I worked at helping people with reptiles they frequently acquired from Pet Cos around the Bay Area, with some of those people telling me a Petco employee sent them. I have had former employees work in my department that came from there.

I know you know everything Ernie but you cant tell me what I have seen and done for years with my days. And sometimes nights.

Yes I would like to know where those animals get industried after their collection from those "few collectors".

And if people who are 'knowledgeable' and 'interested' in reptiles are okay with that, then well, the disconnect is confounding.

NDOW has an incredibly friendly posture towards field herpers and the data they provide.

This is not true. For decades the NDOW has targeted the handful of reptile collectors that reside in the state.

As any reader can see, I said field herpers - more specifically I meant wildlife watchers (ranging from totally casual through "citizen scientist") and sometime sport harvesters. I was not talking about commercial collectors; this should have been clear to readers. These are two completely different communities. In this exchange, you are talking about commercial collectors, and I am not.

Field herpers - especially those more of the "citizen scientist" type - have been actively solicited and incentivized to participate in a variety of NDOW herp programs. Sorry Ernie, it is true. Been there, done that, never seen you there once. I've got the text and email records, the volunteer log sheets, the schwag and awards, and a few photos to prove it.

You're pissed about the python ban, and so am I, as I have said here time and again. But you're talking out your ass on this topic. So why don't you STFU and go get a nice cup of coffee. (Nice avatar, suits you perfectly.)

From the information Jason Jones showed in one of his tables, the species harvested in the greatest numbers by one collector were Horned Lizards, the Leopard Lizard, and Collared Lizard. So I have begun efforts towards calculating ball park estimates of the populations of those species in Nevada.

I have yet to completed that process. But what I have come up with indicates all three species have populations that exceed 92,000. I have looked into the population of the Chuckwalla and preliminary indications are that species also exists in the many thousands in Nevada. Any comments are welcome.

So I wonder if Jason Jones and the other biologists in the NDOW Wildlife Diversity Division would agree that those species have such high numerical abundance in Nevada?

Off and on I have been checking the news about hurricane Irma in Florida as my eldest son Randall and family live in Fort Myers. Just now back to the computer and I see no one has yet commented on my last post.

Although the table produced by Jason Jones mentions ‘Horned Lizards’, I assume the Desert Horn Lizard was the primary species collected. So I will ask if anyone considers my estimated population figure of 92,000 for each species as being too low, too high or about right?

Bryan Hamilton began this thread by posting a link to an article that included a power point by NDOW biologist Jason Jones. However, there is another power point entitled “Commercial Collection of Reptiles” produced by Jennifer Newmark, the head of the NDOW Wildlife Diversity Division? PDF] Commercial collection of reptiles - Nevada Department of Wildlife

The Nevada Independent article mentions the following: “Licenses peaked at 31 in 1994, when registered collectors took more than 31,000 reptiles, a number that has steadily decreased since then. About 7,000 reptiles were removed last year, and now there are seven collectors registered with the state, five of whom belong to the same family.”

The Newmark power point failed to mention the declined of commercial collectors from 31 to 7. Thus her graph only showing a steep decline in the number of collected reptiles produces an erroneous and biased representation. When and where her power point was presented is not known.

Jason Jones used the same graph and visually showed the decline in the number of commercial collectors but without providing the numbers of 31 down to 7. Not having been present at the Commission meeting, I do not know if Jason Jones may have mentioned the decline in the number of collectors. But it is a given he did not tell the Commission that mean number of reptiles collected per collector was nearly the same, 1026 per collector in 1995 and 1016 per collector in 2016.

Besides not having viewed the Jennifer Newmark power point, are others aware there are two additional newspaper articles that covered this issue? So more later.

Richard, I sincerely hope you have received good news from Ft Myers. This must have been a nerve-wracking last few days for you & yours.

As for your abundance estimates, I don't have much to say. Don't know how you derived them, or how you might wish to use them (and presumably some other life history parameters) in some sort of harvest model. That, to me, is the way forward here - use data and modeling to derive some credible sustainable harvest figures, and then take those to the stakeholders. This is in line with my aforementioned preference for agency staff to be the "can we?" people. A technical question, one for the staff to answer. Not the "should we?" people. That is a political decision, not one for staff to make.

What I would caution against, is assuming the harvest effort (or success) is distributed rangewide, in proportion to on-the-ground densities. The harvest is localized, so proportionally speaking, it is more intense than one might assume from using statewide abundance estimates. Similarly, I would caution against any kind of catch per unit effort comparisons. They are invalid, due to the available numerical inputs. Utterly invalid. More below.

This is laughable:

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There are no scientifically reliable ways to accurately estimate reptile population's

Abundance is probably the least useful and hardest-to-obtain wildlife demographic parameter out there. But with good design, adequate effort and suitable data, and appropriate analysis (choice of estimators, choice of statistical distribution, etc), there are a number of "scientifically reliable ways" to estimate abundance. And survival, occurrence, detectability, colonization, extinction, rate of population change, etc etc etc. Ernie, you're out of your depth, you're uneducated - and evidently ignorant - on this topic. If you were educated, or at least informed, on the subject you'd never say something so hopelessly stupid about it.

Switching gears to reported harvests - I will keep repeating myself until someone acknowledges receipt and comprehension. The reported harvests are biased low. I think what is being reported is live exports. Regardless, I am certain there is significant unreported trap mortality - unreported harvest. This is being investigated (by LE) right now. At present it is not known if ~7,000 or ~70,000 reptiles are being removed from living, wild populations per year. What is known, is that there are pitfall arrays out there, each with many traps. You can find live and dead animals in them. Presumably, so can the coyotes, ravens, and other predators - adding to the unknown human-caused harvest (is it unreasonable to assume a snake or lizard escapes predation better when it is not immobilized in an open, countersunk 5-gal bucket?). Because of the condition (mummified or skeletal) and number of dead animals, the frequency of checking these (illegal) traps appears to be quite low. The traps never appear to get closed, presumably they're catching herps from March through October. So even if the commercial collectors are reporting ALL their known captures (highly doubtful, since their collection method is illegal, and their permitted methods would not produce so many mortalities...), there is an unknown harvest fraction as well.

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mean number of reptiles collected per collector was nearly the same, 1026 per collector in 1995 and 1016 per collector in 2016

To make it crystal clear to all readers, not just the intelligent and reasonable ones like Richard, that's what I am disputing. CPUE comparisons just can't be made. For all we know, true effort has gone up. Or maybe down. Or maybe it is the same. We don't know that.

What we do know, is that today's reported effort is extremely under-reported. Trap-days would be the honest denominator in that equation. What's getting reported is pure horseshit, from a management-utility standpoint. 100% pure equine fecal matter.

As for the decline in licensees from 31 to 7 - maybe the quitters quit because you can't make enough money at this if you actually follow the law. Or, maybe the CPUE of whatever capture methods they were using back then, declined to the point of "economic extinction"? Maybe they were guys who started in the 60s and they just got old, and they retired? Who knows why they quit? It would be interesting to interview them. I wonder if the proportion of scofflaws in the population of collectors was as high then as it is now. Is, now. Is. Ernie, enlighten us, wouldya? You know everything. Tell us a story why don't ya?

There are different ways to look at public utilization and ensuring continued access, I think. Assuring the populations remains available for personal collection, photography, and ecological services would be included. If commercial collection is compatible with the above, then perhaps it should be allowed also? It sounds like an all too common situation though were it's either ON and OFF. That is really regrettable that our society has become so unreasonable that we can no longer compromise and I think that goes way beyond reptiles and what we are discussing here is but one of many examples. If we could get enough unbiased, reasonable people in the room, surely all would walk away a winner, but it seems that is now the exception. Richard provided *decades* of evidence in the case of Oregon but they instead chose to ignore evidence and go with a predetermined position citing a vet of all things a source. While he may be great at working on horses, does anyone really think that he knows more about rubber boa populations than Richard? I know I am citing an individual example but I cannot help but believe that it is representative of a larger problem where the best information does not get the highest consideration. The problem with ignoring the best possible information is that it means that unbiased decisions go out the window. "your side" may "win" today but things can end up swinging completely the opposite way, too.

If the predetermined position of the biologists has something to do with animal welfare maybe it would help to try to understand it. There seems to be a mysterious gap involved in relations that at its best is filled in with trivializing broad brushed characterizations.

There is science involved in animal welfare issues - population dynamics is not the only reality explored in scientific examination. Behavioral ethology, neurobiology, and other interdisciplinary fields of animal function can only create more interest and depth to the knowledges many seem more comfortable exploring.

If people are really interested in forging something other than the present adversarial stance. Maybe trying to understand something, rather than forcing oneself to block things out before even finding out what it is.

There is no need to fear becoming more generous. The more preoccupied we are about what we want as humans the less time there is for insights about other organisms.

There are different ways to look at public utilization and ensuring continued access, I think.

Absolutely. The main role of stakeholders is to bring the different ways - what they want to be allowed to do - for consideration. The main legitimate roles of a state wildlife agency are, IMO, to 1) ensure process integrity such that that constructive/nonexclusive minority desires are not steamrolled by majorities, and 2) to ensure continued access by all stakeholders who can be accommodated. Note that role 1 would not permit an antihunting majority - or minority - to dictate that another stakeholder group be denied the type of access they desire.

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Assuring the populations remains available for personal collection, photography, and ecological services would be included.

Well put - especially the last item. State wildlife agencies endure a terrible conflict of interest which makes them hostile to predators of big game and sportfish, for example. But predators have ecosystem roles to play. However, from a tactical standpoint I prefer to stay away from functional arguments, because a common - and often effective, though factually dubious - counterargument is that human hunters can replace the function of other predators. IMO it is more effective, in arguing for the existential rights of top predators, to select emotional or philosophical tactics. "They just have a right to exist. Full stop, period." That argument is actually in accord with public trust doctrine, and more importantly, usually statutorily embodied in the mission of wildlife agencies. Perpetuating such vaporous notions as "ecosystem services" is not. You gotta go with what works legally, and not get tangled up in theoretical - and often empirically shaky - functional arguments.

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If commercial collection is compatible with the above, then perhaps it should be allowed also?

The problem with ignoring the best possible information is that it means that unbiased decisions go out the window. "your side" may "win" today but things can end up swinging completely the opposite way, too.

I also agree with this, particularly the pendulum part, but quibble with the notion of "best possible information" being an objective thing. To me, to stop or dampen the pendulum requires the adversaries/competitors to each come away with something to be satisfied with. Even if that is "just" being treated fairly. I and probably many - even most? - people can accept being beat fair and square. People can in fact can be good losers, not just poor losers. It's called good sportsmanship. But getting beat by cheating? I am your absolutely implacable enemy, for life. I reckon it's like that for many - even most? - people. Myself, I do not want implacable enemies. At least not ones I cannot justifiably kill. So - be fair and honest.

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If the predetermined position of the biologists has something to do with animal welfare maybe it would help to try to understand it.

Understand yes, but maybe - or maybe not - condone. IMO the only legitimate animal welfare considerations for a state wildlife agency biologist pertain to the period of time between the granting of a license or permit, and the exercising of that "chance". I.e., for the "hunt" period. IMO once the animal has been transferred from the public domain to the private, once it has been "taken", the agency staff should step out of the picture. Stakeholders and politicians can continue in that role, but my personal feeling is that staff should step off at that point. Periodic inspections of exotic or dangerous animals are different - there is a public welfare and wild-resource responsibility there. But IMO if you e.g. take a native snake out of the wild, you should not need to e.g. submit annual reports about that animal. Whether the animal is alive in a cage, or pickled in a museum jar. (Yes, the latter happens some places; it seems silly to me. Actually, the word "silly" trivializes it - actually, this requirement infuriates me.)

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There is science involved in animal welfare issues - population dynamics is not the only reality explored in scientific examination. Behavioral ethology, neurobiology, and other interdisciplinary fields of animal function can only create more interest and depth to the knowledges many seem more comfortable exploring.

Sure, but this blurs the lines between "can we" and "should we". So those realities outside of population dynamics need to be advocated by stakeholders and politicians, and not staff. In my opinion.

I have been at this a long while. There are whole fields of quicksand and tar to ensnare the earnest but incautious public-servant biologist. I always tell people, you can work for PETA and that's fine. You can work for fish and game and that's fine. But you cannot be employed by fish and game, and at the same time serve PETA. I would show PETA the same consideration, were circumstances reversed. "Be fair and honest - no cheating."

First, all of the posts I have submitted in this thread are more for my benefit than for others. In my attempt to review issues, I find it helps if I put my thoughts in writing. In that regard, I will be submitting a series of posts that pertain to this issue.

The more I have delved into what has transpired, I find this issue more and more disturbing. With perhaps the exception of Ernie E., I don’t believe anyone else really grasps just how unprofessional and unethical is the situation that has occurred. At least 3 media articles have appeared presenting just the one side of the issue. Did these media sources learn of this issue at a Commission meeting or were they contacted by Wildlife Diversity Div. personnel?

I have been working on a communication for the Nevada Board of Wildlife Commissioners. By going over all facets of this commercial harvest issue, it has helped me with what I will be conveying to the commissioners. Besides the Commission, I may be sending my communication to one or all 3media outlets.

And in back tracking some, I noted the Jones power point document is labeled, “Jason L. Jones Herpetologist 23 June, 2017 Commission Update” The other power point document by Jennifer Newmark show the following: “Nevada Board of Wildlife Commissioners August 11, 2017”

From the dates shown, it seems that the Newmark document may have been produced from and after the Jones document. And were both documents presented before the Wildlife Commission, to some other audiences, or what?

Some time ago, I considered trying to contact the head of the NDOW Wildlife Diversity Division, Jennifer Newmark, to see if she would change her stance if I were to present her with information she had not considered. Today, I Goolged her name and came up where it describes her appointment as the administrator of the Wildlife Diversity Div. and her background profile.

With respect to her background, if there is a classical case of putting the fox in charge of the hen house, the Newmark appointment to head the NDOW Wildlife Diversity Div. is a classical example. I also found a web page that provided her email address.

So in keeping with my original decision to contact her, I did so this afternoon along with copies to the NDOW Director and Board Chairman. Anyone give me odds whether or not I will hear back from Ms. Newmark or the other two individuals?

Richard F. Hoyer==========================================================================Ms. Newmark,On August 30th, I was informed of the following link. https://thenevadaindependent.com/articl ... tion-rules

As a wildlife biologist and field herpetologist having conducted and published research, I naturally have looked into this issue. Years ago, a similar issue was discussed at length on the once PARC List Serve web site. So I am well versed on this subject having contacted biologists in Florida (Kevin Eng) and Louisiana (Dr. Jeff Boundy) who have been involved in the commercial take of reptiles and amphibians in their respective states.

The formation contained in the Jason Jones document and the similar power point document you produced do not provide any valid evidence that would support the position that reptile populations have been harmed by the commercial harvest over the past 30 years. In fact, the information presented in both documents provides evidence to the opposite, that reptile populations remain numerically abundant and at decent densities. For individuals not having been involved in herpetological research, I can understand why they can have the perception that commercial harvesting does harm.

And my own personal bias is that I am not fond of the pet trade in herps whether they originate from commercially harvest or captive breeding. But despite my negative feelings about the profit motive involved in commercial take, I nevertheless am able to analyze issues in an objective manner.

The graph you presented showing a decline in the number of reptiles harvested between 1995 and 2016 does not represent a decline in species numbers but only that fewer reptiles were harvested. That information is easily explained by the fact that the number of licensed commercial collectors also declined from 31 – 7. I suggest you divide the number of reptiles collected in both years by the number of collectors and see what that tells you.

I have prepared a draft of comments for the Nevada Board of Wildlife Commissioners and / or possibly for some media outlets. My comments are very critical of efforts towards having the Commission alter or abandoned the current regulations dealing with the commercial take reptiles. The reason for my criticism is the total lack of a science-based approach. Before I submit those comments, I am contacting you, the NDOW Director, and the Board Chairman to see you will delay the hearing on this issue before the Commission until you have had time to review my analysis and comments.

I have always taken the stance that individuals behave in an honest manner until I discover differently. So I have taken for granted that you actually believe that reptiles have been harmed due to commercial take and that you perceive the information you submitted as proof. But that position is completely false and at complete odds with biological realities and basic concepts of wildlife science.

If I do not hear back by the end of this week, then I will proceed as originally planned. And as is my long standing practice, feel free to copy this communication to whomever you wish.

Richard I hope you are OK. Some of your responses strike me as a bit obsessive and that concerns me. I don't know you personally though but I wanted to check in.

Jimi you mention that "could" and "should" are two different questions. That's true. But I think we should discuss the "should".

Does anyone besides Kelly want to discuss what happens to the reptiles after they are collected? How about the 105,093 horned lizards that starved to death in captivity? Or the chuckwallas that go to slaughter for asian medicine? Or all the bycatch from the pitfall traps, which would constitute wanton waste if they were game animals?

Bryan,You very well could be right, that I am going off the deep end. But isn’t that to be considered normal for a person about to turn 84 (next month)? I know it is only wishing thinking on my part, but I would really like to see the conservation movement return to ethical standards.

What irks me no end is for wildlife agency personnel falsely presenting (faking) information as if such were science-based. That is precisely what is occurring in this Nevada issue. I have yet to have anyone explain in rational terms, what is wrong with being honest.

Just wait Bryan until you see what I have in store next for this thread. I advise you hold on to your sanity as I may push you to the brink. Hah!

Good to hear. I try to keep a sense of humor with all this. I eagerly await your next move. Is it related to the veiled threat that something will happen if you don't get a response in a week?

You and I have very different opinions on this issue of collection and what is ethical. Science can't answer the question of right or wrong. I get the impression you think there is a right answer and that you have it. If only others could understand!

Jimi you mention that "could" and "should" are two different questions. That's true. But I think we should discuss the "should".

Does anyone besides Kelly want to discuss what happens to the reptiles after they are collected? How about the 105,093 horned lizards that starved to death in captivity? Or the chuckwallas that go to slaughter for asian medicine? Or all the bycatch from the pitfall traps, which would constitute wanton waste if they were game animals?

Is this really the kind of "field herping" we support here?

Hi Bryan. Good to hear from you. I was just in Ely last Friday, passing through from around Mammoth. Got some good rain. Enjoyed the train museum and some excellent pizza. Thought about you & yours over the hill in Baker (we ran up to Wendover & across from there). Enjoyed some of Tonopah Brewing Co's Ghost Pepper IPA (hot stuff, if you like the burn).

As for "we" - yes this is largely a stakeholder forum. So to discuss the "shoulds" here - and express personal preferences - seems perfectly appropriate. Now as a herp-loving stakeholder, of course I don't appreciate horned lizards starving to death in captivity. They don't have to. It's definitely something that can be reduced a lot (to get the rate down to almost zero would require well-enforced strict zero possession limits for all would-be users). But I still don't think that's a realm that the staff of an agency that permits the harvest of horned lizards ought to be mucking around in. If the Board wants to weigh in, or the stakeholders want to weigh in, that's another matter entirely. And my preference for their votes or their decisions would be, to not prohibit any levels or forms of access & use that don't reasonably appear likely to cause an existential problem for the wildlife populations. In the case of horned lizards, I'd rather leave it up to the herp-keeping community to develop better ways to feed captive horned lizards. I mean, think about it. We wouldn't know anything about herp husbandry if extreme animal-welfare folks had existed and gotten their way, from the early days of herpetoculture until now. You get better by trying, failing, feeling the pain of failure, and being allowed to keep trying.

I think my personal inclinations stem from an old-school live and let live mentality: "I might not like what you want to do. But I'll be damned if I'm going to let you dictate what I can and cannot do. And as I cannot abide hypocrites, I will attempt to not be one. Therefore, I guess I'll just have to live with you doing what you like, as long as you show me the same consideration."

Obviously such thinking & acting only go so far - we cannot tolerate rapists, murderers, kidnappers, thieves etc. And we need to respect the legitimate rule of law, and the institutions that enable and sustain it. But actively living with such a mentality can take us a ways down the road of peaceful cohabitation - particularly among competing interest groups.

Speaking professionally now, as a manger - I maintain that state wildlife agency staff, for the most part, really ought to stay out of the "should" business while they're doing their jobs of integrating wildlife needs and people needs. A principal reason is that is supremely difficult to successfully navigate being a manager and a stakeholder on the same issues at the same time - there are simply too many perceived - & sometimes actual - conflicts of interest, which threaten to erode public trust in the agency & indeed IMO in the very institution. (Just pay attention to some of Ernie's posts, if you can stomach them for a minute, if you want to see proof of my words - whether or not he has actually been cheated and lied, he believes he has been. That is the source of his venom and hate and paranoia.) In my professional opinion it is far, far better for "a feeling manager" (i.e., every single one of us) to recuse oneself from one role or the other. Most working people would rather keep their job, and I cannot support taking a paycheck but not actually working for it, so I always recommend recusing oneself from the stakeholder role in such sticky situations.

My recommendations are often violated - I see it a few times a year. It's entirely appropriate for stakeholders to call managers out when that happens. But - for self-interest as much as common civility - they need to do it without a flamethrower. And managers need to be able to call out stakeholders who are inciting them to act outside the bounds of proper management (happens all the time, trust me). But again - without a flamethrower.

It can be seen that Jones and Newmark appear to perceive that the numbers of reptiles harvested represent a decline in reptile populations. Such an interpretation demonstrates a lack of critical thinking.

Richard F. Hoyer+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ Nevada To Consider Banning Or Limiting Commercial Collection Of ...“According to Jason Jones, a state herpetologist, data from collectors’ logs show reptile populations are dwindling and reptile hunters must spend more days in the field collecting animals than in the past.”-------------------------------------------------------------------------------------------------------------------Nevada studies changes to reptile collection rules – Las Vegas ...““From a biological perspective, it’s hard to think there’s not some impact to local populations,” said Jennifer Newmark, administrator of wildlife diversity for the Nevada Department of Wildlife.

Jason Jones, a herpetologist with the state Wildlife Department, said data from collectors’ logs show that the return is not as good as it once was, and hunters must spend more days in the field to gather enough reptiles. Those anecdotes suggest reptile populations are dwindling, Jones said. Over the last 30 years, an average of about 14,000 reptiles have been collected annually, with a high of about 35,000 one year. “When you have that level of collection in one state, it’s likely to have some impact,” Jones said””-------------------------------------------------------------------------------------------------------------------

Bryan,As I mentioned previously, I have always had reservations about the pet trade in reptiles and amphibians. The profit motive can produce problems along with the very reason you mention. I venture to say that most captive specimens either end up dying of neglect or when individuals lack the know-how in caring for the species they purchase.

But being a biologist and believing I know something about populations, I am also aware that the overwhelming percentage of young of all species die within a year or two of birth or hatching. But they at least have some chance of living out their natural lives under natural conditions. That has been one of the underlying reasons that during my research, other than donate specimens for vouchers, virtually all other snakes have been returned to where they were initially captured. To this day, I get a bit of a ‘high’ in recapturing ‘old friends’ that I have seen many times in prior years.

I get the impression that perhaps yourself and others believe I am pro commercial collecting as I am opposed to the position taken by the Nevada Wildlife Diversity Division. That would be a misunderstanding as my opposition is based on the ethics and professionalism of wildlife agencies.

In searching the NDOW web sites, one site mentions the principle of “Scientific Management of Wildlife”. I challenge anyone to show me where the Wildlife Diversity Division is using a science-based process in their effort dealing with the commercial collecting of reptiles in Nevada.

You will have to wait as I am still working on the series of posts where I will throw you my ‘curve’ that may give you the ‘squirms’. He he.

Jimi,As I just now posted, I have been working on a draft for this thread in which I attempt to provide a different method for understanding the current issue of commercial harvest of reptiles in Nevada. The first draft was sooooooo long that I will break it into a series of posts. I am not finished with reviewing and revising so as I told Bryan, he will have to wait until he becomes ‘unhinged’ with what I convey. Hah.

And all of what I hope to convey pertains to the very topics you mention in your first paragraph and to some degree, in your last two paragraphs. As for your second paragraph, many years ago on the former national PARC List Serve, I produced a number of 4 – 5 essays dealing with the issue of collecting. I believe the second or third essay had to do with my analysis of the factor of demand.

One of the points I mentioned is that collecting mainly takes place where there is ready access, thus mainly along and near roads. And in the document by Jennifer Newmark, she mentions that fact as being a negative. In contrast, I consider that situation as being a positive. Can you come up with a reason why the concentrated collecting efforts along and near roads would represent a biological ‘plus’?

But IMO if you e.g. take a native snake out of the wild, you should not need to e.g. submit annual reports about that animal. Whether the animal is alive in a cage, or pickled in a museum jar. (Yes, the latter happens some places; it seems silly to me. Actually, the word "silly" trivializes it - actually, this requirement infuriates me.)

I'd love to see examples of those annual updates:

Quote:

2017: still dead.

Switching topics,

Richard F. Hoyer wrote:

You very well could be right, that I am going off the deep end. But isn’t that to be considered normal for a person about to turn 84 (next month)?

Don't make it sound so negative. I think the term you seek is "eccentric." It sounds much more classy.

There are no scientifically reliable ways to accurately estimate reptile population's

Abundance is probably the least useful and hardest-to-obtain wildlife demographic parameter out there. But with good design, adequate effort and suitable data, and appropriate analysis (choice of estimators, choice of statistical distribution, etc), there are a number of "scientifically reliable ways" to estimate abundance. And survival, occurrence, detectability, colonization, extinction, rate of population change, etc etc etc. Ernie, you're out of your depth, you're uneducated - and evidently ignorant - on this topic. If you were educated, or at least informed, on the subject you'd never say something so hopelessly stupid about it.

OK- I’ve had a chance to read this thread and I believe it’s now time for me to weigh in here.

1) The current regulations allow for unlimited bag limits for every species of native reptile, except for a handful that are protected under state law (Desert Tortoise, Gila Monster, Sonoran Mountain Kingsnake, etc.). The main critics of this proposal seem to be arguing that 1) the NDOW brief is bad, there are no demonstrated impacts to native herps, and 2) therefore the status quo of unlimited bag limits should continue. At the August Game Commission meeting the Commission tasked NDOW to provide 2 options for their consideration: 1) A plan to end commercial reptile collecting in Nevada and 2) A plan to more closely regulate it, presumably with some combination of bag limits, closed seasons, and/or closed areas in the state.

2) Jason Jones provided at least 3 extensive briefs to the Game Commission over the past year – at their request. As the agency expert he remained neutral and simply provided the data. I attended two of the briefings- one in March and one in August - and a great deal of data was also provided verbally in the discussion, as the commissioners were engaged and asked a great deal of questions. After the March meeting we took the commissioners out in the field and showed them a series of the illegal pitfall trap lines that are utilized by the commercialists. The one powerpoint you all are arguing over provides an overview of that brief but important details were discussed and aren’t on the slides. Also there was a brief in June I was not able to attend and additional data and issues were discussed. Critiquing one of Jason’s three powerpoint briefs, and without the context of being present and hearing the additional dialogue is analogous to critiquing the 9/11 commission report after you’ve only read chapter 1. I applaud Dr. Hoyer’s efforts to start some research into this, and to begin a dialogue with the commission, however the commission meeting is barely a week away. That train “left the station” months ago, so to speak. Not to sound overly critical, but you’re not a Nevada stakeholder, and 11th hour complaints from non-residents probably won’t carry much weight.

3) Also stated early in the thread, and taken unquestioningly as fact since, is that Jason’s data shows that take has steadily declined, yet the level of effort by individual commercial collectors remains unchanged. On the contrary we have compelling evidence showing the commercial collectors level of effort has increased dramatically, yet their yield has continued to decline. They have used 2 “force multipliers” over the past 15-20 years to increase their take: A) Pitfall traps- a few NDOW volunteers began finding pitfall trap lines about 24 months ago. Game wardens then began searching, and additional searches by some of us have identified more than 700 traps. The trap lines lie suspiciously close to two-trac roads along which the commercial collectors report very heavy take. The condition of buckets found often varies- some are brittle, having clearly been exposed to the elements for at least a decade. Other buckets clearly have been in service for 5 or fewer years. There was an example in the commercial collector data from Amargosa Valley where a couple of Chionactis where reported being collected between 10AM and noon in June. Who finds Chionactis on the surface at 10AM in June? I don’t recall the exact date but I believe it was 2005 or 2006 data. Clearly pitfalls have been in use at that location since at least that time. Analysis of the commercial collectors self-reported data identified a number of these inconsistencies, and would explain heavy pitfall use (nocturnal species being collected during daylight hours). I believe the commercial collectors placed a trap line or two, and upon its demonstrated success continued to add more trap lines over several years as they were successful, went undetected and received no adverse repercussions. I believe there are likely well over 1000 traps in Amargosa Valley and adjacent areas. As the number of traps grew to huge numbers, there are too many to ethically manage properly (i.e. close them when not in use). Not that there is any evidence that they even attempted such efforts. B) Multiple collectors operating under one license- One truck of such collectors was caught by a warden last year and given a warning. I know a buddy who was out herping a couple of years ago and observed a truck full of collectors had kids jump out with nooses and start chasing lizards. I believe the family that is involved in most of the commercial collecting got “smart” and figured why should the family buy 6-10 licenses each year when 1-2 will suffice? Given NDOW’s lax enforcement of even modest regulations, I’m not surprised they do this. Yes, last year only 7 commercialists bought licenses and made the required reports to NDOW. However, the actual number of individuals actually engaged in commercial collecting was probably much higher.

Under Nevada Administrative Code (NAC), both these actions are illegal. To date and to my knowledge they have not been held accountable for any illegal activity. Several of us have debated with Jason just how much these illegal methods have contributed to their overall take, but I believe it to be substantial. They would not continue to install large numbers of pitfall over successive years unless they were seeing a substantial return on these efforts. I believe where the commercial collection data shows a spike in take in 2000-2001 is where these illegal “force multiplier” methods came into widespread use. I also believe they probably poach in nearby areas in adjacent CA, bring the take over the state line, and report it in NV. The data shows that despite these increases in their level of effort, their reported take continues to decline over time. The nearest analogy I can think of is fisheries management where an area is allowed to be overfished. Despite increased fishing boats and level of effort, the fisheries yield continues to decline over time.

4) When I was stationed in Vegas in 2003-2005 I made several trips out to the Amargosa Valley and the Amargosa Dunes. I was impressed by the abundance of lizards in the valley and around the dunes, especially Desert Iguanas, Horned Lizards, Leopard Lizards, and Zebra-tailed lizards. Being a recreationalist and herping for the enjoyment, I simply searched and noted what I found. Since retiring and moving back to Vegas in 2013 I have made a several trips back to the same area, and to several other locations in the Amargosa Valley. Being more disciplined I now measure my level of effort. 9 days and 31 man-hours of searching over 2 seasons, I have found a single horned lizard, a single leopard lizard, and 2 desert iguanas (Zebra-taileds and Whiptails are still abundant). That level of effort would have produced several times that number of these lizard species in 2003-2005. There are also areas of similar high-quality looking habitat in California where I can go and in 30 hours of search effort find dozens of desert iguanas. I can’t speak to northern areas of the state and other remote areas where less frequent collection has been reported, but from my personal experience the Amargosa Valley has suffered dramatic lizard population reductions. If it’s not due to commercial collection, I have no alternate explanation. However, my personal observations are consistent with Jason’s analysis of the commercial collectors’ data in Amargosa.

5) Hobbyist/Non-commercial collection. I place myself firmly in this camp. Nevada’s “default” bag limit for hobbyists for most herps is 2/yr. This is more restrictive than the “default” for states like CA and AZ (4/yr), or UT (3/yr and a possession limit of 9). Yet at the same time commercialists are entitled to unlimited bag limits?? The fact is the status quo is simply unsustainable. As a Nevada resident, voter, and constituent, I am entitled to the same access to this public wildlife resource as the commercialists. If they depopulate large areas and now I cannot observe them in the wild for my personal aesthetic and citizen-science reasons (even if they are not yet extinct), then the Commission and NDOW have failed at their fiduciary duties. At an absolute minimum, a more equitable balance between hobbyist and commercial interests needs to be established.

6) Nevada Wildlife Action Plan (WAP). The 2012 update added 7 or 8 herp species to the list of “species of conservation priority” (SOCP). Jimi is right in that this is a non-regulatory document and confers no special protection to any of the SOCP. The 2012 update was put together either before Jason was at NDOW or shortly after his arrival. I’ve had a number of discussions with him on the document and its shortcomings. Why are banded geckos and sidewinders SOCP? Especially the banded gecko, which is essentially a nocturnal Uta- it’s one of the most abundant and widespread herp species in Nevada. Why did they leave the Lyre snake off? – it’s secretive, difficult to find, and a habitat specialist so this species probably should be a SOCP. Those critiques aside, while the discussion of the WAP was interesting, it has no direct bearing on the commercial collecting issue at hand.

7) Some of the species-specific discussions: Chuckwalla- some areas where commercialists have reported large take have been searched by other NDOW volunteers. I have searched one such site. Number of Chucks observed per level of search effort is very low at several sites searched. So contrary to Richard Hoyer’s uniformed assertion, impacts have been documented. Horned Lizard- Desert Horned lizard is the one assumed to be collected on most reports (based on habitat/geography short-horned lizards are excluded as candidates in most data provided by commercialists). The ethical issue of collecting large numbers of a lizard for the pet trade where their primary diet (ants) cannot be provided for by the overwhelming number of owners of such lizards is problematic. I support a zero bag limit for them. Let some other state sacrifice thousands of their horned lizards in an effort for ZooMed to produce an effective formic acid diet supplement.

8) I find Ernie and Richard’s combination of NDOW conspiracy theory and pseudo-science complaints rather amusing. NDOW basically gave up on any sort of management of reptile commercial collectors after they lost the 1999 battle (badly mis-stated by Ernie, but it would be a whole separate post to lay out the timeline factually). Game wardens put absolutely zero effort into enforcing the existing regulations since then, and the commercialists’ reports were simply filed away and never even given a critical look – until it came on the commission’s radar, Jason dusted off these old reports, and began charting take over time and applied some quantitative analysis of the numbers. Even now the LE side is extremely timid in taking any enforcement action. Note only the warning given when multiple collectors were observed operating under 1 license. When I talked to an LE, he said he could give out fines, but he would probably be laughed out of court by the judge. This is the fundamental problem on the criminal enforcement side- cultural perception of reptiles as worthless and of no value. Now if we could only grow furry feral lizards and populate our wildlands with them, then PETA and HSUS would have shut down commercial collection a decade ago.

Here’s my bottom line: I have no problem if the commission places bag limits, closed seasons, or other reasonable restrictions on commercial collection. As I’ve stated, at a minimum a more appropriate balance needs to be achieved between hobbyists and commercialists. However, given their blatant flaunting of the law, I also have no problem if the commission kills commercial collection entirely. They place huge numbers of pitfall traps and don’t even bother to close them when they’re not using them?? Leaving them open 24/7/365, they not only cause unnecessary losses to their desired catch, they cause completely unnecessary losses of bycatch. In short, they don’t give a shit about public wildlife resources. Perhaps part of this is the profit motive. It seems commercializing wildlife incentivizes this illegal behavior. Perhaps its karma. They’ve been so blatant with illegal conduct and arrogant in their approach maybe the commission will be forced to spank them. However, even with this momentum I put it at a less than a 50/50 chance the commission kills commercial collection entirely. Partly it’s that the commercialists are pushing back hard, and partly it’s the inherent bias to status quo in these sorts of public stakeholder actions – fundamental shifts are very hard to make in such beauracracies, and the bias toward compromise makes the middle option the most likely. The devil is in the details- there is an awful lot of trade space in the “increased regulation” compromise. The commercialists are asking for bag limits of 1500 or more for some of the lizards they have historically collected in large numbers. That’s where you are going to see the fight over the next week.

So- Nevada residents – I encourage you to write the commission. If you support ending commercial collection, tell the commission. If you think hobbyist deserve a seat at the table, tell the commission. If you support improved regulations but think bag limits of 1500 for Horned Lizards or 500 for Chuckwallas are still outrageous, tell the commission.

For everyone else – it’s a free country with first amendment freedom of speech, so you are also free to write the commission. As I stated earlier it’s the 11th hour and non-Nevada resident voices probably won’t carry much weight (as it should be, in my opinion).

And for everyone- this is a Field Herp Forum- consider this a standing invitation to anyone who is sincerely interested in this issue. If you ever visit Nevada I would be willing to take you to some of these areas in the southern part of the state and show you first-hand illegal pitfall trap lines, and how depopulated these pristine-looking habitats are.

Steve,I found your post as very well thought out and reasonable. I mentioned somewhere that assessing situations long distance has hazards. So some of the details you mention certainly are of importance. For some reason, I did not consider that it was the commercial collectors that were installing the pit fall traps and considered they were abiding by the stipulated methods of collecting. Just dense I guess. Thanks of the insight.

Your rational about hobbyist having a bag limit whereas the commercial collector have none is of particular of interests as it should be just the opposite. Years ago, I contacted all western states to determine what permits were required to collect and conduct research on the Rubber Boa. It was a long time ago but I believe Nevada did not require a permit but did have a bag or possession limit. The number seven comes to mind but perhaps it was only 2 or perhaps 4 at that time.

My objections were mainly two fold. The first is where wildlife agencies state they manage species of wildlife via sound-science. Their web sites will have a stated principle indicating the agency manages wildlife via science-based process. Nevada is no exception. But then I find that agencies do not abide by their principles and assertions of managing species via sound-science.

My second objection is where agency documents infer that collecting could produce negative impacts to the overall population of reptiles in Nevada. That is complete nonsense!

That local populations can be over collected is a given as per your example about over-fishing indicates. I have has that happen to many of my Rubber Boa research sites over the past 55+ years.

Steve S. Below I have copied what was mentioned at the end of the article that accompanied the power point document by Jason Jones.

It was this narrative that led me to believe that the pit fall traps were not a critical issue. That is not to say the unwarranted and unnecessary loss of animal life constitutes unethical behavior on the part of those that deploy and fail to monitor such traps. One possible way to help solve that issue would be to ban such traps for the collection of scorpions.

But unless there is some evidence that would indicate otherwise, I am still of the opinion that such traps are unlikely to be as big of an issue as made out to be with respect to reptile, small mammal, and scorpion (and insect) populations. Such loss of life is akin to the similar issue of road mortality that has been irrationally considered as having negative impact on the populations of many species including reptiles and amphibians.

According to the department, there are more than 700 pitfall traps in Southern Nevada. Pitfall traps, used for collecting insects or in controlled ecological studies, are an illegal method for capturing reptiles. The traps comprise small holes in the ground that blend with the desert. The department has documented reptiles, mice and scorpions falling into these traps.

Of the traps it checked in 2016 and 2017, it found that about half of all reptiles and nearly all mammals that fell into the traps had died. These traps are not permitted, the department said, and a number of them are maintained by reptile collectors. In recent months, nearly 300 have been removed by volunteers and solar developers, but they remain a concern for regulators.

“There is significant mortality of reptiles due to large numbers (700+) of unpermitted pitfall traps,” one NDOW administrator wrote in a memo ahead of the July commission meeting.

The collectors said they used traps to catch unregulated scorpions, a practice that is legal.

Doug Nielsen, a spokesman for NDOW, said there are ongoing investigations.

Steve S.Since you mentioned the that because I am a non-resident and it is too late in the game, then sending input to the Commissioners seems unwarranted. Below was what I had prepared for the Commission but it seems all was just a waste of time. No big deal however. I will just go back to finishing splitting fire wood before the rainy season begins here in Oregon.

One of the Nevada DOW’s guiding principles states the “Scientific Management of Wildlife”.**

Considerations: 1) Regulations on commercial take of reptiles should be revised: A) Set limits on take after NDOW personnel produce estimates of numerical abundance on non-game species of commercial value. B) Consider designating areas or regions in which commercial take is alternated in 2 – 3 year cycles to allow recovery of said species C) Make the use of pit fall traps illegal for trapping of scorpions, D) If allowed by statue, set meaningful fines for first, then subsequent violations of regulations. (Perhaps no less than $2000 for the first violation and a $5000 for subsequent violations.) 2) The Wildlife Diversity Division should be directed to discard all vestiges of using personal opinions in the management of non-game species and adhere to evidenced-based management practices in compliance with the agency’s stated principle. ** 3) Have all Wildlife Diversity Division employees attend a workshop put on by their counterparts in the Game Division in order to gain an understanding that all non-game species, similar to game species, represent renewable wildlife resources. 4) The Wildlife Diversity Division should pursue positive relationships, and work cooperatively with the commercial collecting stakeholders. 5) Give Wildlife Diversity Division personnel a hug (or positive vibes) but then tell them they need to sharpen their understanding of populations.

Supporting Comments: 1) Having Information on ‘supply’ as well as ‘demand’ is essential for arriving at reasoned interpretations and sensible management decisions. The authors of the two power point documents only provide harvest data on the ‘demand’ side. Such data has very little meaning without having reptile population estimates. ## 2) Both presentations convey an anti-collecting bias lacking objectivity. ## 3) Some information of a deceptive or misleading nature and incorrect interpretations occur in both presentations. ## 4) Not understood by most professionals is that species of reptiles with large distributions have numerical populations often numbering in the millions. Consider the following: The 2017 Mule Deer population was estimated at 92,000. Several species of reptiles have distributions in Nevada as great or greater than the Mule Deer. To believe that such reptiles have numerical populations below that of deer is biologically irrational.

A:Jason Jones provided at least 3 extensive briefs to the Game Commission over the past year – at their request. As the agency expert he remained neutral and simply provided the data.

NDOW basically gave up on any sort of management of reptile commercial collectors after they lost the 1999 battle (badly mis-stated by Ernie, but it would be a whole separate post to lay out the timeline factually).

Now if we could only grow furry feral lizards and populate our wildlands with them, then PETA and HSUS would have shut down commercial collection a decade ago.[/

A: I've been offline a bit. So NDOW biologist Jason Jones in s_stocking's opinion was neutral and simply provided the data. LOL. NDOW biologist Jason Jones has clearly been more activist then scientist. Its absurd to claim otherwise. That one statement alone is a testament as to how in unreliable s_stocking information is. s_stocking futher mis-states the truth. Claiming that I said the NDOW basically gave up on any sort of management of reptile commercial collectors after they lost the 1999 battle. That is total BS and provides further insight into s_stocking's ignorance. Lastly. The furry animals in Nevada are allowed to be in some cases trapped or hunted, killed with ZERO resrictions. A license is only required if you sell any part of the animal. The current management of commercial reptiles in Nevada is managed in the same way that furbearer tapping in the state is. Below as reproted in the State of the Union address.

Quote:

By late 1990, the Board of Wildlife Commissioners again directed the Department to permit reptile commercialization in 1991. The Commission re-adopted the justification that in the absence of population information and funding for the Department to obtain the same, a harvest reporting process similar to that for furbearing species would provide distribution and relative abundance information

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You're pissed about the python ban, and so am I, as I have said here time and again. But you're talking out your ass on this topic. So why don't you STFU and go get a nice cup of coffee. (Nice avatar, suits you perfectly.) THE JIMI

As always THE JIMI is wrong. Not just in this small quoted portion of his error filled rantings but across the board. Sheeesh, again I embarrassed him by pointing out his backwards mis-information and he responds by attacking me with more mis-information. Time and time again THE JIMI and other equally ridiculous individuals have tried to call me out and put their foot in their collective months. And true to form these flondering buffoon's. Resort to the old you're pissed about the python ban nonsense to discredit me. When they have been checkmated. Its all they have. Nufff said .

Having met Richard, I can only say that there are few people whom I respect more. Richard does his absolute best to document, document, document, and rely on the facts to guide his decisions even when it does not line up with what his personal feelings. If only more people had that kind of commitment to integrity and ethics, the world would surely be a better place. It should then be no surprise when it bothers him greatly when people state feelings as facts without the evidence to back it up. I think in Richard's world that is a violation of ethics and to be honest on my own view, too. It strikes me that many today do not sure this opinion. As a student in social sciences classes, I could not help but laugh at the experiments conducted which were clearly designed to arrive at a predetermined outcome and from which inferences to the real world were gathered. Conservation science is better than that, but not when people are making sweeping statements without any facts to support them whatsoever. Having said that, it is shame such decisions could not be conducted by reasonable people such as the members here, if that were the case, I am confident we could arrive at a reasonable conclusion where no one were burned too badly. I really hope for a day when facts become more important than emotions or as Jimmi might say the "can" gets at least equal consideration as the "should".

On the other hand, a small dose of common sense could be useful, too. There is little point in collecting horned lizards as most cannot provide the proper care and the few that can would be willing to travel and hand select their own specimens. Perhaps a little dose of "should" would be OK, too? Would anyone be greatly offended if the horned lizard quota were say 100 to only allow for a small group of dedicated, ant catching hobbyist to receive them? If some massive breakthrough is found that quota could always be raised.

Steve S. indicated any proposed comments I might have for the Nevada Commissioners was likely a waste time for two reasons. I was a non-resident of Nevada and that it was far to late in the game. So as I mentioned, I went back to splitting fire wood. I finished that task this morning. So then I went back to working on the series of posts that pertain to my claim that reptile populations often number in the millions.

I just finished that task this evening. As I have mentioned, my efforts are largely for my own benefit. Should others possibly gain from anything I relate, that would be icing on the cake.

Part #1: Background Information:Quite a few years ago, my son Ryan in Utah mentioned I might be interested in joining the national PARC ListServe web site indicating he thought some misinformation / misunderstandings occurred on that web site.

At the time, the PARC membership was comprised of state and federal wildlife biologists, professional herpetologists, conservationists, population biologists, students, an some other stakeholders. The issue of incidental or recreational collecting surfaced and individuals expressed opinions as if fact, that such collecting could produce negative impacts. One very prominent, nationally recognized herpetologist expressed that same position. But not a single individual ever offered, or produced any evidence in support of their opinions / perceptions even though I asked for such.

With individuals expressing such opinions, it came to mind that the individuals that were voicing those opinions were unlikely to have much experience in field herpetology, especially involving snakes and lizard. Having such practical field experience since a kid, it had become very apparent to me just how numerous were many species of herps.

But at the time, is seemed clear that those individuals had no understanding just how immense are the populations of most species of herps. For if they had known, I believe most of them would not have had the perception that incidental collecting could produce negative impacts to the overall populations of herps. These same misunderstandings have surfaced on the Kingsnake forum years ago and on the fieldherp forums.

If you take time to investigate and analyze the issue, it should be realized that before stating that any form of anthropomorphic take (collecting / harvesting / road mortality), has the potential of harming populations, you have to know something about the ‘supply’ (numerical abundance) of a species as well as having information on the take or ‘demand’. I believe that biologists that manage big game species undertake estimates of game species populations. So I ask, why don’t biologists of non-game species attempt to do the same thing?

The Nevada Wildlife Diversity Div. personnel developed documents that depict large numbers of commercially collected reptiles as follows:

Quote from one media article “Over the last 30 years, an average of about 14,000 reptiles have been collected annually, with a high of about 35,000 one year. “ “When you have that level of collection in one state, it’s likely to have some impact,” Jones said.”

Lots of big numbers thrown about but what possibly could such numbers indicate? As implied by the quote by Jason Jones, stating such large numbers is all that is needed to indicate Nevada’s reptile populations are being decimated by commercial collecting.

Local populations can be adversely affected by over harvesting or collecting as has happened here in Oregon when illegal collectors hit some areas.So had the two individuals stated that some regional reptile populations in western or southwestern Nevada appeared to be adversely impacted, that would have been far more palatable. But by implying that the entire state’s reptile populations are at risk is putting forth a false narrative.

That type of deceptive practice, along with the lack of submitting valid, supporting evidence I consider as unprofessional. I have observed the same thing occur in Calif. and Oregon. A year ago June at an Oregon Wildlife Commission meeting, an ODFW employee presented a power point presentation to the Commission members showing NatureServe Ranking information of 6 species of snakes referring to those rankings as being science-based – which is utter nonsense. And the Commissioners believed him and placed all six species in a protected status.

So by presenting the large numbers of harvested reptiles as if those large numbers were meaningful evidence, and then portraying that information in the two power point documents in a way that implies Nevada’s reptile populations are at jeopardy is what I consider as being unethical. Has this type of practice become so common that is it now accepted as the norm in wildlife agencies? It has been my sad experience that seems to be the case. Is Ernie E. and myself the only two individuals that consider such practices assleaze?

That issue aside, back to my claim that reptiles (and amphibian) possess immense populations. I am going to approach the issues of supply and demand (numerical abundance and take) in a different manner that I hope will resonate with everyone. Perhaps just wishful thinking on my part.

Part #2: Deer and Lizards in Nevada:In reviewing the species of reptiles commercial collectors harvest in Nevada, most are species of lizards. Having traveled through a good deal of Nevada at one time or another, much of the habitat in the state appears to be lizard friendly. Yet I assume there are areas in Nevada in which the populations of some species of lizards with state wide distributions do have areas in which they are at very low densities or are absent altogether. Such ‘vacancies’ in distribution would vary with the habitat requirements and other environmental factors that affect the survival of any given species.

Likewise, the distribution of the Mule Deer in Nevada is pretty much state wide. But similar to lizards, there are areas of habitat in Nevada that are not Mule Deer ‘friendly’. So similar to lizard species, the densities and the occurrence of Mule Deer will vary depending on habitat and environmental constraints. And in fact, the species does not seem to occur in some areas of the state. PDF]Nevada Occupied Mule Deer Distribution

Because lizards occur at much higher densities than deer, I hope everyone would agree that lizards, with the same or greater distributions in Nevada as the Mule Deer, would have far greater numerical abundance than the deer population in Nevada. Those species are the Long-nosed Leopard Lizard, W. Fence, Desert Horned, Side-blotched, Sagebrush and W. Whiptail lizards.

So to establish a framework for making comparisons, I first need to establish baseline information dealing with the Nevada Mule Deer population. In 2016, the Nevada Mule Deer population was estimated at 94,000. The number of deer harvested the same year was 7885. I believe deer density is reported as deer / sq. mi. However, reptile density is reported in specimens / hectare (100 m X 100 m or a bit larger than a square football field). So to make comparisons between deer and lizard densities, the deer density needs to be converted to number of deer / hectare.

Even though deer do not occur everywhere across the state, I will use the entire area of Nevada in order to make equivalent comparisons. The area of Nevada is 110,567 sq. mi. By including the area of the entire state, the density of deer in Nevada is 94,000 divided by 110,567 sq. mi. or 0.832 deer / sq. mi. There are 259 ha / sq. mi. so the area of Nevada in hectares is 28,636,853 ha. Divided 94,000 deer by 28,636,853 ha. produces a mean deer density of 0.0033 / ha.

If you know anything about the density of lizards, the figure on deer density / ha. should tell you something. That is, at that density, the estimated deer population was 94,000 in 2016. So with the species of lizards having similar (even greater) distributions as deer in Nevada, at the same density as deer, each of those species of lizards would also have populations of 94,000.

That simple comparison represents the first clue that sheds light on the issue of numerical abundance of reptile populations in Nevada. Also, it represent an indication of just how absurd is the positions taken by Wildlife Diversity Div. personnel expressing concerns about the affect of commercial collecting on the overall reptile populations in Nevada.

Now before I go any further, there will be individuals that have the urge to say that nothing that I will be mentioning would pass as being scientific, subject to statistical treatment, publishable, etc. etc. And that would be correct. But what I have covered thus far, and will cover from here on has everything to do with an analysis of available information, critical thinking, and the ability to reason --- all of which are important aspects in scientific endeavors.

In my prior post, taking into account the total area of Nevada in hectares, the estimated, mean density of Mule Deer in Nevada was calculated to be at 0.0033 Mule Deer / ha. And as mentioned, the 2016 Mule Deer estimated population was 94,000. That information provides sufficient evidence for making some reasoned determinations about some Nevada reptile populations.

If each of the six species of lizards with distribution nearly the same or in excess of the Mule Deer, only had mean densities of 0.0033 / ha., in Nevada, then each of their populations, at a minimum would also be about 94,000. But with lizard densities being far greater than that of deer, it then should be clear that the populations of the species of lizards with distribution over most of Nevada, have populations far in excess of 94,000. But how much greater is the next question and one I will address a bit later.

That information gives insight with respect to the issue of commercial collecting and its potential impact on reptile populations. Consider the following: Of the 5 lizards in which Ms. Newmark produced harvest data, three of the species have distribution that extend over most of the state.

By dividing the mean yearly harvest numbers of those three species by 94,000, a comparison can be made between their harvests rates and that of deer. The lizard harvest rates are, Desert horned lizard - 3.7 % (3503 / 94,000), Long-nosed leopard lizard - 2.2 % (2034 / 94,000), and W. Fence Lizard - 1.4 % (1353 / 94,000). In 2016, there were 7885 deer harvested for a harvest rate of 8.4 %.

Jimi indicated that the number of each commercially collected species likely was under-reported. So by doubling the estimated mean harvest numbers of each of those three species, their harvest rates would then be double or 7.4 % for the Horned Lizard, 4.4 % for the Leopard Lizard, and 2.8 % for the Fence Lizard, all below that of the harvest rate for Mule Deer.

I assume (hope) everyone understands that the 94,000 base-line estimate of lizard populations represent a gross understating of all such populations. And when one produces estimates of a more realistic population size of those lizards, then the harvest rates would hardly be worth a footnote.

Research describing the methods for ascertaining species’ densities vary from being very complex to being very simple such as just counting members of a species over an area of known size. But researchers are reluctant to provide estimates of overall populations. However it is my understanding that biologist in the game divisions of wildlife agencies, by various methods, do produce population estimates of some game species.

There is a simple, predictive model by which anyone can arrive at reasoned, ball park estimates of numerical population size. All you need is to come up with reasonable values for the density of any particular species and the area of occupied habitat. Density figures can be obtained from published research. But producing estimates on the area of occupied habitat throughout a species distribution is more problematical. But in both cases, in order not to arrive at potentially inflated population numbers, the lower range of densities for any species should be used and a conservative to ultra conservative value for area of occupied habitat should be used.

I was going to produce such a estimate for the Chuckwalla population in Nevada. In searching for Chuckwalla densities, I found a number of published densities including one in which the Chuckwalla density at Lookout Mt. near Phoenix was determined (over a number of years), simply by counting basking lizards on a 5 hectare plot. A table was showed the counts varied from 11 to 14 in different years. So that I could cite the paper, I went back to Google but could not find that exact paper with that table.

Because the area in which the Chuckwalla occurs in southern Nevada is difficult to estimate, I switched gears and instead chose the Long-nosed Leopard Lizard for this example. The Leopard Lizard distribution in Nevada, similar to the Mule Deer, basically covers the entire state. So like the Mule Deer example, I will first use the entire state in hectares for my baseline frame of reference between the two species.

For figures on Leopard Lizard density, the species was reported to occur at from 2.47 to 4.94 / ha. in southern Nevada and 19 / ha. in Utah. (“In the deserts of southern Nevada, Turner et al. (1969) found densities ranging from 1-2 adults/ac (100-200/100 ac, 247-494/100 ha).” “Densities in northern Utah were even higher (19/ha, 8/ac; Parker and Pianka 1976) than those in southern Nevada.”)

The species appears to be able to reach fairly high densities such as that reported in Utah. And in June of 2015, those herpers that were on the S. Kern Plateau witnessed just how numerous is the species in the vicinity of Kennedy Meadows. But for my purposes here and to be conservative, I will only refer to the Nevada data on density. Note that the mean density would be 3.7 lizards / ha. If we were to reduce that figure to just one lizard / ha. and apply it to the area of the state in hectares, then the overall Leopard Lizard population in Nevada would be estimated at 28,636,853.

I can almost hear some on this forum saying ‘No Way’. So, I suggest others compute their own estimate of the Leopard Lizard population by inserting varying estimates of Leopard Lizard densities and estimates of the amount of area occupied by the species in Nevada. Here is an example. Say that the species actually only occurs in just 1/4 of the state’s total area or 7,159,213 ha. Then at a mean density of just 1 lizard per ha., the population of the species would then be 7,159,213. Now I suspect that figure of over 7 million Leopard Lizard in Nevada may not be conservative enough for some individuals.

So let’s say that the Leopard Lizard occurs in only 1/10th of the state’s area and has a mean density of 0.2 lizard / ha. So 28,636,853 ha. X .10 = 2,863685 ha, X 0.2 lizard / ha. = 572,737 Leopard Lizards. If you cannot grasp that the figure of 572,737 for the Leopard Lizard population in Nevada as being insanely under-stated, I suggest some critical thinking needs to take place.

Now if I have learned anything from the past from the PARC experience and on these forums, I can almost hear the ‘screaming’ that such a process is not scientific, wouldn’t stand up to peer review, etc. ,etc. And of course, that certainly is correct. But I suggest that this simple predictive model is not all that far removed from the methods employed by the researchers that produced the density figures of the Chuckwalla population on Lookout Mt. near Phoenix.

This process is not meant to be presented as publishable results but solely meant to provide ball park estimates on numerical abundance. That is, the method is meant to gain a reasoned understanding of just how immense are the populations of reptiles (and amphibians). Although not publishable in scientific sense, such estimates do provide a reasoned method for gaining insight that wide ranging species of reptiles have exceeding large numerical populations. Anyone can toy around with this predictive model for any of the other species for which you can find density figures. The key is to always use conservative values for densities and ultra conservative values for area of occupied habitat.

Part #5: Final Analysis:So I now refer back to just now totally nutty is the perceptions by NDOW personnel who implied that the commercial collecting of reptiles can harm the overall populations of reptiles in Nevada such as the Leopard Lizard. Consider the following: From the document by Jennifer Newmark, it shows that the total number of Long-nosed leopard lizards harvested in Nevada from 1986 – 2016 was 60,410. And as mentioned previously, 60,410 divided by 30 years indicated a mean of 2014 Leopard LIzards per year were harvested.

Now I will again address the concerns about the number of lizards being under-reported and / or not reported. It the number of Leopard Lizards that were not reported was equal to the reported number, then the yearly average of harvested Leopard lizards would be 4024. But then let me add another 2014 lizard to that total that were run over, illegally collected, removed by other members of the public, etc. Then the number of annual take would amount to 6014 Leopard Lizards removed annually from the overall population.

So the annual ‘harvest’ rate would be 6038 divided by 572,737 or 1.05 %. Now compare that figure with the harvest rate of 8.4 % for the Nevada Mule Deer population in 2016.

Such an analysis should tell everyone just how irrational is the notion that collecting of reptiles in Nevada harms the overall populations of such species. Now I can already hear voices say that the collecting does not happen over the entire state, may be concentrated in certain areas, occurs near roads (as was mentioned by J. Newmark) etc. I again suggests you sit down and think more about this issue. And if the above does not resonated and is not informative, so be it.

Richard F. Hoyer

P.S. If someone can point out mistakes, and if such cited errors are indeed true, I have no reservations in admitting to such errors and making amends. RFH

Pretty much all the lizard species targeted for collection in Nevada require very large enclosures, knowledge of light wavelengths and spatial strategy, and a myriad of details that are only perfunctorily addressed or not at all in care sheets often created by people who have had one or a few with unaccountable success.

Lizards usually end up bought by the consumer because of the way they look. They are usually housed in rinky dink "Kits" with a fixed output heat lamp and a cheap coil UV bulb. They are usually handled and played with to listless exhaustion - not only by children but adults too, who mistake their malaise for being friendly.

I could write 100 posts one after another and still not cover the consequences I have seen.

If there are millions and millions of reptiles in Nevada that is splendid.

I hope for the day when any of those can run across an expanse of native land, land that they have evolved in and that not one of those millions fall into a bucket stinking of putrescine from the past remains to die or suffer because of the petty desires of my kind.

Richard's long and interesting post went into greater detail discussing some of the key points I previously touched on. A point that should be made clear that has been misused by some posters has been the referencing the use of illegal pitfall trap lines by the collectors. It is legal to use pitfall trap lines in Nevada for the collection of scorpions as the collectors claim they are currently using them. There is as much evidence to support the collectors claims as there is to support the claims of misuse. If anyone had sound and credible evidence that the collectors have been using these pitfall trap lines in an illegal manor as claimed by NDOW biologist Jason Jones. We wouldn't be having this discussion. The collector's would have been charged with a wildlife crime. Jason Jones has once again intentionally presented speculation and his personal narrative as fact and others have wrongly followed suit. .

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The more I have delved into what has transpired, I find this issue more and more disturbing. With perhaps the exception of Ernie E., I don’t believe anyone else really grasps just how unprofessional and unethical is the situation that has occurred.

I think based on all the side stepping of the obvious unprofessional and unethical behavior displayed by NDOW biologist Jason Jones. Its not a question of grasping, it is more truthful to say that some individuals are just unwilling to own up to the wrong doing. They have proven track records of this displaying this type of behavior.

Unlike others. I have not weighed in as to how I think things should be handled from a personal standpoint. I have stuck to analyzing and commenting on the situation based on how it has been handled in the past, it is currently being handled and the definable lack of science, objective fact based critical analysis and the influx of bizarrely off color content etc. Found in NDOW Biologist Jason Jones presentation. Notice how the NDOW/Jason Jones supporters will refuse to acknowledge any of this. Instead they focus on long winded speculative "explanation's" that ignore clear truths and biologically sound principles and employ various other school yard tactics. This is a stock pattern of behavior from these individual's when they are cornered.

In the past the Nevada Board of wildlife directors have for the most part appear to have been objective and based there decisions on the presented facts. It is improvable "not impossible" that this will be the case this time. All things considered, todays out of control media that will try to generate click bait bad publicity based on the tabloid style science of NDOW biologist Jason Jones, the threat of costly lawsuits from the horrifically deplorable Center for Biological Diversity, the gross deception etc. The Nevada Board of wildlife directors could willingly not choose to do the right thing once again but knowingly take the politically correct and easy way out.

What are the rules on pitfall traps in NV (assuming people wish to legally use them for scorpions)? Many other forms of passive collection/harvest for other species in other states (e.g. juglines, crab traps, etc.) must be marked with the owner/user's name and address, thereby allowing accountability by that person.

If it were me, and I found a pitfall trap with no such information, it'd be a relatively easy matter just to remove it and fill it in--much easier than it was for the user to build it in the first place. It could even be a citizen-science project (free labor!) organized by NDOW, since they're apparently knowledgeable of the locations of numerous such traps.

If the traps are not being used by commercial herp collectors (as they claim), there should be no problem and we won't see any change in annual take of the species in the presentations. It would be a chance to confirm or deny the traps' actual use; essentially "calling out" violators as well as discouraging their use (since it's fairly labor intensive to build the traps, they may abandon their use out of mere impracticality--not worth their time). Sounds like a fairly win-win situation all around--a forcing-function to ensure compliance with existing law without needing additional regulation, and reduction of bycatch and waste of wildlife resources due to deaths in the traps.

Do scorpion/invert collectors have to report numbers caught? I doubt it, but I'm curious.

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